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Code of Conduct Act with Spirit and Integrity

Be Accountable

Be Respectful

Comply with the Code


Code of Conduct

CONTENTS Message from the Chairman & CEO 1.0

Values, Principles and Standards

4.0 Accountability

1.1

Compliance with laws and regulations

4.1

1.2

Code of Ethics

4.2 Company Assets

1.3

UN Sustainability Goals

4.3

Non-public information

4.4

Conict of Interest

2.0 Respect 2.1

Equal Emplt Opportunities

2.2 Personal responsibility 2.3 Managers responsibility

Financial Records

4.5 Fair competition 4.6

Information Technology

4,7

General Data Protection Regulation (GDPR)

3.0 Spirit and Integrity 3.1

Industrial Relations

3.2 Enthusiasm 3.3

Knowledge

3.4

Trust

3.5 Honesty 3.6

Consistency

5.0 Additions 5.1

Raising Concerns

5.2 Failure to comply with the Code 6.0 Acknowledgment 7.0

Approval

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Message from the Chairman and CEO – Elvin Bugge Dear Colleague, Aquatiq® has become a strong brand within the Food Safety industry and our contribution has put us in a key role to achieve high food standards. This work is based on confidentiality and trust, which means that we all need to focus constantly on this Code of Conduct. We shall continuously act with spirit and integrity to secure our internal and external development and actions. Our vision “What it Takes” reflects the attitude in our daily work and is an inspirational platform in all our activities. Our mission “Supplier of complete Food Safety solutions and expertise” replicates our ambition and ability to be at the forefront of the Food Safety Industry. Our business is built on high ethical reputation and we need to maintain and improve this in the future. “Passion for Pure”, is our slogan to care for our globe and the decreasing amount of pristine nature. We are obliged to have this in mind during all our projects and supplies. This Code of Conduct is our guide to ethical conduct. In addition to these guidelines, each and every-one shall seek guidance in situations. Together, we shall continue to be at the forefront regarding ethics, trust and integrity.

Kind regards,

ElvIN BUGGE


1.0 Values, Principles and Standards vision: “What it Takes” Our vision is “What it Takes”. This vision commits us to promote quality and pride in the work we do. Furthermore, we are committed to each other and our customers by constantly working towards a “pure” and sustainable way of innovating our solutions. Mission: “Supplier of complete Food Safety solutions and expertise” Our ethical statement is “Passion for Pure”. We work with companies across the world to ensure safe food production and aid companies to promote long term, sustainable solutions for a better future. We act with integrity by doing what is right. By doing this, we positively reflect the values and reputation of the company in all the countries we are represented. We shall strive to do “What it Takes” for Aquatiq® and our customers. The Code of Conduct is a guide to the values, principles and standards we want to promote in our operations and all dealing with our customers. The Code of Conduct addresses our responsibilities to our company, to each other, customers, suppliers and the environment. We realise that the Aquatiq® approach to Food Safety is quite unique. Considering the experience and our strong team of professionals, it’s our ambition to strive for superior quality and aim to be at the forefront of the Food Safety Industry. 1.1 Compliance with laws and regulations We must all follow the laws and regulations in the countries we operate. We will act with integrity, respect and honesty in every aspect of our job


Code of Conduct

1.2 Code of Ethics “Passion for Pure” 1.2.1 Food security: Our goal is to ensure safe food across the world. The world population is growing faster than ever and by 2050, will have reached 10 billion people. This commits us to ensure Safe Food, and achieve superior solutions that promote sustainability and guarantee the wellbeing of the environment and its people. 1.2.3 Environment: We acknowledge that some of our products have an impact on the environment. However, we believe that through knowledge, correct training and endorsement of environmentally friendly products we reduce our impact on the environment. Furthermore, we work with certifications that commit us to act in the best interest of the global environment and social standards. We are committed to comply with all applicable laws and legislations for a sustainable planet. We strive to implement energy efficient solutions and have implemented waste management in all our offices. 1.3 UN Sustainable Development Goals At Aquatiq®, we believe that the respect of human lives stands above everything else. With this in mind, we understand the importance of what we do has a real impact on human life. We are a positive advocate of the UN Sustainable Development Goals, and can make a positive impact on many of these goals.

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2.0 Respect We are all responsible for promoting high standards of behaviour in the business we conduct. Aquatiq® is committed to maintaining a diverse workforce and promote Equal Employment Opportunities for everyone in our company. We will promote a workplace environment that is free from all kinds of discrimination. This includes gender, race, ethnic origin, nationality, sexual orientation, religion, age, disability, marital status, and other instrumental values. Furthermore, we shall be an open and transparent organisation, which support one another regardless of background and ethnicity. At Aquatiq® we shall: l

Always show respect for all stakeholders involved in our business. l Promote diverse cultures. l Stand up for what we believe is right – in a respectful and solution orientated manner. 2.1 Equal Employment Opportunity Gender Equality “The Act shall promote gender equality and aims in particular at improving the position of women. Women and men shall be given equal opportunities in education, employment and cultural and professional advancement. The law is based on the principle of nondiscrimination, which is the cornerstone and basis for promoting gender equality” Sexual Orientation & Anti-Discrimination “The Act relating to a prohibition against discrimination on the basis of sexual orientation, gender identity and gender expression (the Sexual Orientation Anti-Discrimination Act) entered into force on 1 January 2014. It applies to all areas of society apart from family life and the private sphere.” The Working Environment “The new anti-discrimination regulations added to the Working Environment Act protect against labour market-related discrimination on the basis of gender and ethnic origin etc., as well as on


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the grounds of disability, sexual orientation, age and political conviction. The act also ensures employees the entitlement to leave of absence during pregnancy and childbirth” Other acts to be aware of: l The Human Rights Act l Representation of all sexes on all official committees etc. 2.2 Personal responsibility Everyone working for Aquatiq® shall strive to exercise good judgement, behaviour and attributes. You are expected to comply with the Code of Conduct and perform your duties in line with the principles and standards set forth in the code. If in need of advice or consultancy regarding an ethical dilemma, you are advised to seek guidance with your supervisor or other appropriate authority. Considerations: l

Is it ethical? l Is it legal? l Will it reflect well on the company? l Is it consistent with the Code of Conduct? 2.3 Managers’ responsibility Managers are responsible for communicating the requirements in the Code of Conduct to all employees. Further, managers are responsible for promoting the Code of Conduct in the everyday operations and lead by example. All Aquatiq® directors shall ensure that all employees are familiarised with the Code of Conduct and that the Code is read and understood. l

Ensure that people understand their responsibilities under the Code of Conduct. l live the brand and be a positive advocate for the Code of Conduct. l Create an environment where employees feel comfortable raising concerns. l Act to stop violations of the Code of Conduct or the law by those you supervise.


3.0 Spirit and Integrity Spirit and integrity is the core of our values as a company. We seek to act with spirit and integrity in every aspect of our operations. We strive to be hard working, inspired and sharing in our profession. Furthermore, we are truly passionate about developing the best solutions and create value for all stakeholders. By acting with integrity, we do what is right. Moreover, this reflects positively on our values and reputation everywhere we operate. Acting with integrity involves doing what is right for ourselves, and for Aquatiq®. In doing so, we are all required to follow the law, act with spirit and integrity in all matters of our business, and be accountable of our actions. 3.1 Industrial Relations “We aim to be Part of the Solution for a long term sustainable and profitable Food Industry” Over its lifetime, Aquatiq® has created long-term relationships with our customers. This is reflected in our values, which promotes a close relationship with our customers to find the best solutions. As a result, we constantly work to improve our solutions and create value for our customers. lastly, we strive to establish long-term partnerships based on mutual respect and understanding with our customers, and aim to be responsive to customers’ needs and interests. 3.2 Enthusiasm “We believe that enthusiasm creates a better work environment, which is reflected in our culture” We are passionate about what we do and believe that the work we conduct is impacting the society in a positive way. This creates a passionate company environment that endorses our purpose. Furthermore, enthusiasm is a core value of our operations, promoting persistence and pride in our work.


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3.3 Knowledge “Knowledge through experience and research” Innovation and research is top priority in our company. We live in a rapidly evolving world. To keep up with industry demand, we need to constantly improve our solutions. We are looking to enrich our employees’ abilities through acquainting them with the latest industry trends. In doing so, we aim to be the most knowledgeable supplier in the industry. We strive to attract employees that bring innovative knowledge into the company and employees that will drive our development. 3.4 Trust Trust is key in every aspect of our operations. We shall be known as a trustworthy and reliable organisation. Furthermore, we take pride in keeping our agreements and strive to create value for our customers. We acknowledge that mistakes will be made, but will do “What it Takes” and constantly pursue improvement. We aim to be ‘Just and Fair. Fairness is concerned with actions, processes, and consequences that are morally right, honourable and reasonable. We will do this by considering our moral standards for decisions that affect others. In addition, we will consider ‘Biases and Prejudice’ before making a decision based on appropriate manner with appropriate criteria. 3.5 Honesty We shall compete fair and openly. By competing on the quality of our goods and services, we uphold Aquatiq’s reputation. We will not limit the competitive opportunities of our competitors in any deceitful or dishonest way. We seek to win business based on the quality in every aspect of the work we do. 3.6 Consistency We believe that consistent quality will ensure long lasting relationships. Aquatiq® shall be a company that is trusted amongst customers and suppliers. Consistency is the core of our identity and should shape our performance on both an organisational and individual level. We take pride in our work and will use this to keep our promises. All will strive to do “a little more” for our customers. This is reflected in our vision “What it Takes”.


4.0 Accountability As an organization, and as individuals, we are responsible for our activities and actions. Although human error may occur, we will do our very best to act professionally in every aspect of our job. In addition, we strive to implement accuracy and to disclose the results in a transparent manner. Accountability also includes responsibility for money and/or other company assets. 4.1 Financial and Business Records Ensure the accuracy of all business and financial records. This also includes quality reports, time records, expense reports, benefits claim etc. The financial reports and other information that Aquatiq® maintains internally must be accurate and complete. Everyone is responsible for ensuring accuracy and transparency when dealing with financial records. Accurate recordkeeping and reporting reflects AGG’s reputation as a highly credible company. Furthermore, it ensures that the company meets its legal and regulatory obligations. l

Record and classify transaction in the proper accounting period. Do not delay or rush the recording of revenue or expenses to meet budgetary goals. l Ensure the credibility of all reports. Furthermore, they must be full, accurate, timely and understandable. l Never falsify any document. l Only perform transactions such as buying and selling assets, which have been authorised l Co-operate fully, transparent and honestly with external/internal auditors, tax-authorities and other regulators. l Do not interfere in second party efforts to evade taxes or make arbitrage on insider information. l Follow laws and regulations according to the countries we operate in. l Strive for accuracy 4.1.2 Accuracy in Recordkeeping Employees must ensure the presentation of accurate information when preparing records for the company. An intentional effort to falsify business records is a violation of the Code and law.


Code of Conduct

4.2 Company Assets Protect the Company assets and use them in the manner intended and outlined by the company. Do not use company assets for personal benefits, or for anyone outside the company. Exemption from this rule only applies when granted managerial permission. Examples of Company Assets: l Company money l Company product l Employees’ time at work and work product l Computer systems and software l Telephones l Wireless communication devices l Photocopiers l Company vehicles l Company Information 4.3 Non-public information Non-public information is any information that the company has not disclosed or made generally available to the general public. Examples of non-public information that should NOT be made public: Inventions l Contracts l Strategic business plans l Mergers and acquisitions l Technical specifications l Pricing l Proposals l Financial records l Product cost l

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4.4 Conflict of Interest “We take pride in Aquatiq’s reputation and consider the firms best interests in our outside engagements and activities” Act in the best interest of Aquatiq® while performing your job for the company. A conflict of interest might arise when personal activities and relationships interfere with the ability to act in the best interest of the company. Outside of Aquatiq®, no activities shall be pursued if such activities interfere with the interests of Aquatiq®. 4.5 Fair Competition Aquatiq® and its subsidiaries shall comply and follow the competition laws and regulations. We are committed to promote fair and open competition. We believe in transparent competition and we strive to outdo our competitors through honest and fair business. Further, we shall not make false or misleading accusations about our competitors. 4.6 Information Technology Everyone must ensure the responsible and secure use of IT in Aquatiq®. We must ensure a professional conduct when using the Internet, intranet, social media and email in the name of the company. In Aquatiq® we must ensure that: l Passwords are kept confidential. l Caution is taken when dealing with sensitive information. l Obtain permission from any employee before posting or publishing personal infomation about them. l Ensure that additional storage or software is approved and licensed.


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4.7 General Data Protection Regulation (GDPR) The aim of the General Data Protection Regulation (GDPR) is to protect all EU citizens from privacy and data breaches in an increasingly data-driven world. The key points of the GDPR as well as information on the impacts it will have on business can be found in a seperate document for the Aquatiq Group.


5.0 Additions & Actions Who must follow the code? The Aquatiq® Code of Conduct applies to all employees of Aquatiq®. This includes all major owned subsidiaries. 5.1 Raising Concerns Everyone is obliged to uphold the values, standards and principles of the Code. If any violations of the code or unethical behaviour occur, we encourage you to raise the issue with your management. There will be no retaliations against you, or any impact on your professional career, for reporting violations in good faith. 5.1.1 Confidentiality Every individual is encouraged to speak up if any violation with the Code is detected. These matters will be confidential and shall remain anonymous. However, in most cases there will be no need for anonymity and the case can be dissolved in a healthier manner if the process is open and honest. Furthermore, any employees who raise a concern honestly cannot be victim of any adverse employment action. This includes, suspension, loss of benefits, threats, harassment, demotion or discrimination. 5.1.2 False Accusations Aquatiq® will protect all employees who raise a concern honest and faithfully. However, it is a violation of the Code to make false accusations. Everyone is expected to provide accurate and truthful information when raising concerns.


Code of Conduct

5.2 Failure to Comply with the Code “We will consult the Code, comply with its requirements and seek guidance where needed” It is each employee’s responsibility to ensure full compliance with all provisions of the Code. To do “What it Takes” and “What is Right” to ensure the highest standard of integrity is each employee’s personal responsibility that cannot be delegated. When in doubt, employees should always ask a supervisor for guidance. Any failure to comply with our Code may result in disciplinary action, including the possibility of dismissal and, if warranted, legal proceedings or criminal sanctions.

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6.0 Acknowledgment I herby understand that it is my responsibility to read, understand and to keep up to date with the Aquatiq® Code of Conduct. Furthermore, I will seek clarification or further information, if needed. lastly, I will comply with the contents of the Aquatiq® Code of Conduct. I acknowledge that I have received a copy of the Aquatiq® Code of Conduct for my personal review. Furthermore, I understand that breach or violations of the Aquatiq® Code of Conduct may result in disciplinary actions as stated in the code. lastly, I acknowledge that I have been afforded the opportunity to ask any questions I have regarding the Aquatiq® Code of Conduct.

NAME

DATE

SIGNATURE


Code of Conduct

7.0 Approval The Code of Conduct was approved by the Aquatiq® Board of Directors: December 2017. Aquatiq® AS Aquatiq Consult AS, Aquatiq Chemistry AS, Aquatiq Hygiene Systems AS, Aquatiq Hygiene Systems ltd, Aqua Pharma AS (Norway), Aqua Pharma Inc. (Canada), Aqua Pharma ltd (Scotland/UK), Aqua Pharma Chile SpA, Aqua Pharma Australia ltd, Aqua Pharma Ireland ltd, Aqua Pharma US Inc, Aquatic Hygiene ltd (Scotland/UK), Aquatiq Food Factory AS, Aquatiq Food Factory DK, Aquatiq Food Automation DK, Aquatiq Australia Pty ltd, Aquatiq International AS, Mediterranian Aquatic C.O.O, TX-Guardian AS, Haugaland Shipping AS Adr: Hovemoveien 1, N-2624 lillehammer, Norway e-mail: post@aquatiq.com / www.aquatiq.com Tel: +47 61247010

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Aquatiq AS Hovemoveien 1, 2624 Lillehammer www.aquatiq.com

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